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Buy §48E Clean Electricity Investment Tax Credits: 2026 Buyer Guide
Quick answer
A §48E clean electricity investment credit can be sold for cash under IRC §6418 to an unrelated buyer, who claims it against federal income tax. The credit is 6% of eligible basis, or 30% with prevailing wage and apprenticeship compliance or a project under 1 MW, plus possible bonuses. Buyers pay a discount to face value and diligence recapture risk.
The §48E clean electricity investment credit (the "ITC") is the main federal credit for new solar, wind, energy storage and other zero-emissions power projects placed in service after 2024. Project owners can sell it for cash under IRC §6418. Veritas focuses on helping C corporations, passive income investors and their CPAs buy §48E credits at a discount to face value.
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What a §48E credit is
- Rate. The base rate is 6% of the qualified investment. It rises to 30% for projects that meet prevailing wage and apprenticeship rules or are under 1 MW AC, and bonus credits can add 10 percentage points each for an energy community and for domestic content (IRS; §48E(a)). See the bonus rules.
- Timing. It is determined for the year the facility or storage is placed in service and claimed on Form 3468 by the owner; a buyer reports the purchased credit on Form 3800.
- Applies to. Facilities and storage placed in service after December 31, 2024 (IRS). Projects that began construction before 2025 can still claim the legacy §48 credit instead: compare them.
- Not both. A facility cannot claim the §48E investment credit and the §45Y production credit (IRS).
- Transferable. The owner may sell the credit once, for cash, to an unrelated buyer under §6418. The buyer gets the credit at less than face value; the price is not deductible.
Where the supply comes from in 2026
Third-party market data from Crux (August 2026) shows the mix shifting toward storage. These are Crux's figures, not Veritas's:
- Standalone battery storage grew to 7% of transfer volume in H1 2026 from 5%, and solar-plus-storage to 12% from 5%.
- Solar was 30% of volume (from 35%) and wind 7.5% (from 23%).
- Crux estimates developers safe-harbored more than 170 GW of wind and solar before the July 4, 2026 deadline. Those projects keep §48E or §45Y eligibility if they are placed in service by about 2030.
- Crux forecasts tax credit supply above $75 billion a year through 2030, with storage and §45X manufacturing credits growing to nearly two-thirds of supply by then.
That is why a buyer who wants a block of credits for a particular tax year often finds more to choose from in §48E than in the narrower credits. Read the side-by-side comparison of §48E with §45X, §45Y, §45Z, §45Q, §45V and legacy §48, including where each is the better fit.
What buyers must weigh
- Five-year recapture. If the property is sold, stops qualifying or is destroyed within five years, part of the credit can be clawed back from the taxpayer who claimed it, which is the buyer (details and protections).
- Foreign-entity rules. Facilities and storage that begin construction after 2025 cannot include material assistance from a prohibited foreign entity (§48E; Notice 2026-15). Crux reports this risk has become the main driver of pricing.
- Wind and solar deadlines. New wind and solar must have begun construction by July 4, 2026 or be placed in service by December 31, 2027 (what to verify).
- Price. Crux put the market average for 2026 ITCs at $0.913 per dollar of credit in H1 2026, below the historical $0.920 to $0.925 range, with legacy §48 credits at a premium (pricing guide).
- Your own tax capacity. A credit only helps up to what you can use: the §38(c) limit for C corporations, the passive-activity rules for individuals.
Who buys §48E credits
C corporations
Use purchased credits against regular federal tax, subject to §38(c).
Passive income investors
Offset tax on passive income only; we screen for that first.
CPAs and advisors
A review framework and diligence package for your client file.
How a §48E purchase works
- Size your capacity with your CPA: tax year, amount, active or passive.
- Get indicative offers for §48E credits matched to that year.
- Run diligence on the project, seller and foreign-entity position.
- Sign a transfer agreement with indemnity and, where appropriate, insurance (key terms).
- Pay cash and report the credit on Form 3800 with the transfer election statement.
Other credits: if you came here looking at §45X, the §45Y production credit or another transferable credit, we cover them honestly and show when §48E is, and is not, the better match. Overview of the credit itself: the clean energy ITC explained.
- §48E Tax Credit Pricing and Discounts: What Buyers Pay in 2026
- §48E Due Diligence Checklist and Recapture Rules for Credit Buyers
- §48E vs Other Transferable Credits: How Buyers Compare Them in 2026
- How a C Corporation Buys §48E Credits: Capacity, Timing and Accounting
- How Individuals With Passive Income Buy §48E Credits (and Who Should Not)
- A CPA's Guide to §48E Tax Credit Transfers: Screening, Review and Reporting
- §48E Energy Storage Tax Credits: What a Buyer Should Know
- §48E Solar and Wind Deadlines After July 4, 2026: What Credit Buyers Must Verify
- §48E vs Legacy §48: What Is Different for a Credit Buyer
- §48E Bonus Credits: Prevailing Wage, Energy Community and Domestic Content
- §48E Transfer Agreement: Key Terms for Credit Buyers
- Production tax credit vs investment tax credit: PTC vs ITC for buyers in 2026
- What is the low-income housing tax credit (LIHTC), and can you buy it?
- CAMT and purchased §48E tax credits: what corporate tax teams check
- §48E credit indemnity and insurance: what the buyer bears and what to ask
- Portfolio §48E credit deals: buying credits from more than one project
Frequently asked questions
Can I buy §48E tax credits?
Yes, if you have federal income tax liability you can use. Under IRC §6418 the owner of a qualifying project can sell the credit once, for cash, to an unrelated buyer. The buyer claims it on Form 3800. How much you can use depends on your entity type and tax position.
How much do §48E credits cost?
They sell at a discount to face value. Crux reported a market average of $0.913 per dollar of credit for 2026 ITCs in the first half of 2026; Cenet Capital cites roughly $0.895 for early 2026 with investment-grade sellers at $0.92 to $0.95. Actual prices depend on the seller, deal size, insurance and foreign-entity risk. Those are third-party figures, not quotes.
Is §48E different from §48?
§48 is the legacy energy credit for property whose construction began before 2025. §48E is the technology-neutral credit for facilities and storage placed in service after 2024. A single facility cannot claim both. Legacy credits are exempt from the new foreign-entity rules and have traded at a premium.
What is the biggest risk of buying a §48E credit?
Recapture, disallowance and foreign-entity exposure. Recapture can apply for five years after the project is placed in service, and the buyer who claimed the credit bears it unless the contract shifts it. Diligence, a no-fault indemnity and insurance are the usual protections.
Who should not buy §48E credits?
People without enough federal income tax to use the credit. For individuals, purchased credits are passive activity credits, so wages and portfolio income generally do not qualify. Our eligibility quiz screens for this first.
- IRS: Clean Electricity Investment Credit (§48E)
- 26 U.S.C. §48E, Clean electricity investment credit (Cornell LII)
- 26 CFR §1.48E-1, Definition of energy property and rules applicable to the energy credit (eCFR)
- 26 U.S.C. §6418, Transfer of certain credits (Cornell LII)
- IRS: Elective pay and transferability FAQs, Transferability (Q4-Q15)
- IRS Notice 2026-15, interim guidance on material assistance from prohibited foreign entities
- Crux: 2026 mid-year market intelligence report, 5 takeaways (Aug. 20, 2026), third-party market data
- Cenet Capital: Tax credit transfer market report, Q4 2026 (Oct. 4, 2026), third-party market data